Risks will be evaluated in international commercial interactions of PETROPERÚ with intermediary companies

In May 2021, PETROPERÚ decided to remove Gunvor (Gunvor S.A. and Gunvor International B.V), a company that supplies crude oil and biofuel, from the Registry of Hydrocarbons and Specialties Marketing Companies. This, as part of the actions framed in its Policy for the Prevention of Money Laundering and Financing of Terrorism, Crimes of Corruption and Anti-Bribery Management, directed by its Compliance Officer.

The Policy for the Prevention of Money Laundering and Financing of Terrorism, Corruption Crimes and Anti-Bribery Management of PETROPERÚ establishes, among other assumptions, not to interact with third parties, whether natural or legal persons (or their main shareholders or directors) who have been sentenced by a final judgment and/or have accepted having committed crimes such as Bribery in the international arena.

As an additional measure, to ensure the company's compliance with Peruvian laws, regulations and policies, PETROPERÚ's Board of Directors agreed to hire Paul Hastings LLP, an American law firm recognized as one of the main advisers in anti-corruption practices, to carry out an investigation diagnoses PETROPERÚ's operations with companies (suppliers or clients) that are linked to processes or possible investigations by the government authorities of the United States, or other foreign authorities.

This contract puts in charge of the North American firm Paul Hastings LLP the development, among others, of the following actions:

• Review and proposal of improvements to PETROPERÚ's anti-corruption risk prevention and management systems.
• Development of alerts, controls, recommendations and efficient practices that allow safeguarding in the best possible way the operations that PETROPERÚ carries out within the framework of its corporate purpose.
• Review of contracts made through a risk assessment (risk study) with third parties, which will include an evaluation of public and internal information to locate potential red flags.

The Paul Hastings LLP Firm - with a presence in the markets of Asia, Europe, Latin America and the United States, has extensive experience in research for oil, gas and mining projects; developing Compliance Programs and Anti-Corruption Investigations throughout Latin America. Paul Hastings is ranked as one of the best firms in the world in The American Lawyer "Premier League" for momentum and prestige among firms in the 2022 American Lawyer 100.

PETROPERÚ emphasizes that it is its priority to strengthen and execute transparency and anti-corruption policies that contribute to improving its performance and Good Corporate Governance.